Collins v. Hennepin County Courts
- Paul Magnuson
- 0:25-cv-02885
- U.S. District Court · District of Minnesota
- 2
In Collins v. Hennepin County Courts, Judge Magnuson dismissed Leon H. Collins's petition to be released from custody without prejudice, adopting the magistrate judge's recommendation.
People who file federal habeas corpus petitions (requests for release from state custody) in the District of Minnesota, particularly those who do not file objections to a magistrate judge's Report and Recommendation, as the failure to object limits the district court's review to clear error only.
What happened
In Collins v. Hennepin County Courts (No. 25-2885), Leon H. Collins filed a federal petition asking to be released from custody, naming Hennepin County Courts as the respondent. United States Magistrate Judge Dulce J. Foster issued a Report and Recommendation on July 23, 2025, recommending the case be dismissed without prejudice. Collins did not file any objections to that recommendation within the allowed time.
Because no objections were filed, the district court was required only to review the Magistrate Judge's Report and Recommendation for clear error — a less intensive review than would apply if objections had been submitted. The court reviewed the reasoning and found no error of any kind in the Magistrate Judge's analysis.
Judge Paul A. Magnuson adopted the Report and Recommendation and dismissed the case without prejudice, meaning Collins is not permanently barred from refiling. The petition for release from custody was denied, and Collins's two applications to proceed without paying filing fees were denied as moot — meaning those requests no longer needed to be decided once the case was dismissed.
The detailed version
- Collins v. Hennepin County Courts · No. 0:25-cv-02885
- Paul Magnuson
- Aug. 27, 2025
Background
Petitioner Leon H. Collins filed a federal petition for a writ of habeas corpus — a legal request asking a court to order his release from custody — against Hennepin County Courts. He also filed two applications to proceed in forma pauperis (IFP), meaning he asked the court to waive the filing fees due to financial hardship.
Magistrate Judge's Report and Recommendation
United States Magistrate Judge Dulce J. Foster issued a Report and Recommendation (R&R) on July 23, 2025, recommending that the matter be dismissed without prejudice. The opinion does not reproduce the Magistrate Judge's underlying reasoning; only her recommendation is described.
Collins did not file any objections to the R&R within the time permitted under District of Minnesota Local Rule 72.2(b)(1).
Standard of Review
When a party files specific objections to a magistrate judge's R&R, the district court must conduct a de novo (fresh, independent) review of those portions. When no objections are filed, the district court reviews the R&R only for "clear error." See 28 U.S.C. § 636(b)(1); Grinder v. Gammon, 73 F.3d 793, 795 (8th Cir. 1996). Because Collins filed no objections, the clear-error standard applied.
Ruling
Judge Magnuson reviewed the R&R and found no error — clear or otherwise — in Magistrate Judge Foster's reasoning. He accordingly:
- Adopted the R&R;
- Denied the petition for a writ of habeas corpus;
- Denied Collins's two IFP applications as moot (meaning those requests became irrelevant once the case was dismissed); and
- Dismissed the matter without prejudice.
Notes on the Opinion
The court's order does not describe the underlying facts of Collins's custody situation, the specific grounds on which Magistrate Judge Foster recommended dismissal, or the nature of any deficiency in the petition. Readers who want to understand why dismissal was recommended would need to consult the R&R itself (Docket No. 4). The dismissal without prejudice means Collins is not barred from refiling, though any future filing would need to cure whatever deficiencies the Magistrate Judge identified.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.